AMERICAN HEALTH INFORMATION MANAGEMENT ASSOCIATION FOUNDATIONNon-Profit

Subrecipient Monitoring H-1B Job Training Grants ? 17.268 U.S. Department of Labor Award Number ? AP-27825-15-60-A-17 Criteria or specific requirement ? Title 2 U.S. Code of Federal Regulations Part 200, Uniform Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance) require the subaward documents to include the terms and conditions of the subaward to ascertain if, at the time of the subaward (or subsequent modification), the pass-through entity (PTE) made the subrecipient aware of the award information required by 2 CFR Section 200.331 (a) sufficient for the PTE to comply with Federal statutes, regulations and terms of the award. Condition ? The documentation given to the subrecipient was lacking information required by 2 CFR Section 200.331 (a). The documentation did not include the CFDA number and the applicable requirements of the Federal Award. Also, required subrecipient monitoring tasks, including determining whether awards were used for authorized purposes and complied with Federal statutes, regulations and terms of the sub award and monitoring of audits was not performed. Questioned costs ? $486,004 ? CFDA 17.268. Calculated as amount passed through to subrecipients. Context ? Of the two of nine subrecipients tested, we noted that neither agreement contained the required information. Furthermore, subrecipient monitoring activities were not being done on any of the subrecipients. Our sampling methodology was not, and was not intended to be statistically valid. Effect ? The absence of subrecipient monitoring activities and lack of information reported in the subaward agreements means the PTE was unaware of requirements and could result in non-compliance. Cause ? The Foundation erroneously completed the subaward agreements and did not complete subrecipient monitoring activities due to lack of understanding of the required information needed for the agreement and subrecipient monitoring activities. Identification as a repeat finding ? Not applicable. Recommendation ? We recommend the Foundation amend all current subaward agreements with PTE to make the subrecipients aware of all the award information required by 2 CFR Section 200.331(a). We also recommend that going forward employees are trained to properly carry out all subrecipient monitoring activities and complete the subaward agreements to ensure all subaward agreements with PTE include all of the award information required by 2 CFR Section 200.331(a). Views of responsible officials and planned corrective actions ? All current subaward agreements with pass-through entities are being reviewed and amended to make the subrecipients aware of all the award information required by 2 CFR Section 200.331(a). This includes them completing a Federal Funding Accountability and Transparency Act (FFATA) form and providing other documentation required by the standards as well as access to verify backgrounds on SAM.gov. Employees tasked with administering subaward agreements will be trained to ensure all policies and procedures are being followed and all necessary information is being captured and maintained.

Allowable Costs H-1B Job Training Grants ? 17.268 U.S. Department of Labor Award Number ? AP-27825-15-60-A-17 Criteria or specific requirement ? An entity may only charge indirect costs to a federal award that would be consider allowable costs. In order for these costs to be allowable, an entity would need to have an updated Indirect Cost Rate Agreement approved by the federal agency on an annual basis. Adequate source documentation should be retained to support amounts charged as indirect costs in order to ensure compliance with allowable cost requirements. Condition ? The Foundation did not obtain an approved updated Indirect Cost Rate Agreement with the federal agency for 2019. The Foundation charged indirect costs to the program during 2019. Questioned costs ? $172,319 CFDA 17.268 ? calculated as the indirect costs charged to the program for the year.Context ? The Foundation had Indirect Cost Rate Agreements approved for previous years, which was the rate used for 2019, but was not approved for 2019. Effect ? Charging of indirect costs without an approved Indirect Cost Rate Agreement can result in the federal agency deeming those costs unallowable. Cause ? The Foundation has experienced a change in management and personnel during the year and the Foundation not following their control procedures. Identification as a repeat finding ? Not applicable. Recommendation ? We recommend that the Foundation implement policies and procedures to ensure that an approved Indirect Cost Rate Agreement is obtained on an annual basis. Views of responsible officials and planned corrective actions ? Policies and procedures around allowable costs are being developed which will include obtaining an approved Indirect Cost Rate Agreement from the appropriate federal agency on an annual basis. These will be routinely reviewed and updated as needed.

Eligibility H-1B Job Training Grants ? 17.268 U.S. Department of Labor Award Number ? AP-27825-15-60-A-17 Criteria or specific requirement ? In order to be eligible for the program, the participants must meet certain educational and competency requirements. Part of the Foundation?s documentation to determine eligibility includes a component that program personnel familiar with program requirements review and approve all participants? eligibility determinations. In addition, certain documentation is required to be in each participant?s files in order for the Organization to be in compliance with their funding agreements. Condition ? Of the sixty files tested we noted the following: Five of the files tested did not contain sufficient documentation to determine whether the applicant was eligible. The applicants in four of the files tested did not appear to have met the competency requirements for inclusion into the program. In addition, nine of eighteen files tested did not contain support for documented review and approval of eligibility determinations. Questioned costs ? Not applicable. Context ? A sample of 60 participants out of 657 total participants were selected for eligibility testing. Our sampling methodology was not, and was not intended to be statistically valid. Effect ? Ineligible individuals may receive service under the federal program without adequate documentation or approval. Cause ? The Foundation has experienced a change in management and personnel during the year and the Foundation was not following their control procedures. Identification as a repeat finding ? Not applicable. Recommendation ? We recommend Foundation management routinely review and consider modifications to or implementation of policies and procedures that would strengthen internal controls surrounding the eligibility process, record-keeping and the management thereof Views of responsible officials and planned corrective actions ? Policies and procedures around eligibility are being developed to address criteria around the eligibility process, appropriate record keeping and ensuring there are management reviews of selected participants. These will be routinely reviewed and updated as needed.

Procurement H-1B Job Training Grants ? 17.268 U.S. Department of Labor Award Number ? AP-27825-15-60-A-17 Criteria or specific requirement ? 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award contains various requirements for procurements made under federal awards. ?200.318 requires a procurement policy be in place with specific requirements. ?200.320 specifies the methods of procurement to be followed, including micropurchases, small purchases, sealed bids, competitive proposals, and noncompetitive proposals. Each procurement method has a threshold where quotes or bids are required to be obtained. Condition ? During our testing, we noted the Foundation did not have a procurement policy meeting the requirements noted in 2 CFR Part 200 ?200.318. Additionally, there were purchases over the small purchase threshold which did not have quotes as required. Questioned costs ? Not applicable. Context ? During our testing, we noted various purchases exceeding the micro purchase and small purchase threshold that did not have quotes obtained as required. Effect ? The Foundation is not in compliance with the requirements of 2 CFR Part 200 ?200.318 and ?200.320. Cause ? The Foundation was unaware of the new procurement requirements. Identification as a repeat finding ? Not applicable. Recommendation ? We recommend the Foundation create a procurement policy in line with requirements, and implement procedures to obtain quotes or bids as necessary. Additionally, we recommend the Foundation maintain documentation of all quotes and bids to support the vendor chosen. Views of responsible officials and planned corrective actions ? A procurement policy is being developed and will be updated periodically. This policy will be in line with requirements and define the thresholds, procedures and information to be collected to obtain quotes or bids as necessary. All the documentation collected will also be stored and maintained to demonstrate the process was followed in choosing the final vendor.

Reporting H-1B Job Training Grants ? 17.268 U.S. Department of Labor Award Number ? AP-27825-15-60-A-17 Criteria or specific requirement ? As part of administering the federal grant programs, the Foundation is required to submit quarterly federal financial reports to the federal agency reflecting current quarter and cumulative grant receipts and expenditures. The reports are required to be submitted within 45 days of quarter end using the accrual basis of accounting and be supported by underlying documentation. Condition ? The quarterly federal financial reports and performance reports were submitted in a timely manner, however, the supporting documentation provided by the Foundation to tie reported expenditures per the financial reports to underlying records did not match reported expenditures for the quarters ending June 30, 2019, and September 30, 2019. In addition, the Foundation was unable to provide support documenting review of reports prior to submission. Questioned costs ? Not applicable. Context ? Two out of four quarterly reports were selected for testing. Of the two quarters tested, we noted that for both quarters, reported expenditures did not tie to underlying support. Our sampling methodology was not, and was not intended to be statistically valid. Effect ? A lack of support for the quarterly financial reports results in difficulty in ensuring amounts reported are correct. Cause ? The Foundation has experienced a change in management and personnel during the year and the Foundation not following their control procedures. Identification as a repeat finding ? Not applicable. Recommendation ? We recommend that the appropriate supporting documentation be maintained to support the receipt and expense amounts filed on the quarterly financial reports. This documentation should be filed and maintained with the copies of the reports. Views of responsible officials and planned corrective actions ? In addition to reviewing the quarterly reports, the appropriate supporting documentation will also be reviewed and maintained to support the receipt and expense amounts filed on the financial reports. This will be a joint effort between the Foundation and Finance teams, with a final review by Executive Management.